Melville Fuller

“ The Constitution of the state of Utah provided that: 'All property in the state, not exempt under the laws of the United States or under this Constitution, shall be taxed in proportion to its value, to be ascertained as provided by law;' and that: 'All corporations or persons in this state, or doing business herein, shall be subject to taxation for state, county, school, municipal, or other purposes, on the real and personal property owned or used by them within the territorial limits of the authority levying the tax.' Const. art. ”

“ The contention on this writ of error is that the taxation of the ten cars of plaintiff in error was forbidden by the Constitution of the United States because they had no situs for that purpose in the state of Utah, and the tax imposed a burden on interstate commerce. ”

“ Rep. 599, quotations were made from the opinions in Pullman's Palace Car Co. v. Pennsylvania, 141 U.S. 30, 35 L. ed. 619, 3 Inters. Com. Rep. 595, 11 Sup. Ct. Rep. 876; Adams Exp. Co. v. Ohio State Auditor, 165 U.S. 194, 41 L. ed. ”